Insurance Law

9th Circuit: In ERISA case where appeal period ended on a Saturday, filing deadline becomes Monday

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Saying that a rule often applied to court filing deadlines also makes sense in administrative ERISA matters, a federal appeals court Thursday revived a former FedEx worker’s disability benefits case.

Because a 180-day period for Andre LeGras to appeal the termination of his benefits ended on a Saturday, the mailbox rule should be applied and the deadline extended to the next business day, the San Francisco-based 9th U.S. Circuit Court of Appeals held in its Thursday opinion (PDF).

That meant the appeal mailed by LeGras to AETNA Life Insurance on the Monday after the Saturday deadline was timely.

“Incorporating this time-computation method into ERISA’s federal common law protects the interests of insureds, thereby effectuating the policy goals of ERISA. Further, the concept is generally accepted and vital,” the opinion states.

A dissent says the court should have adhered to the Saturday deadline.

Hat tip: Courthouse News.

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